Fifth Circuit Upholds Dismissal of Suit Against Mississippi County Over Jail Prisoner's Death
Complaining of nausea and vomiting, Princess Anderson arrived at the emergency room (ER) of the Baptist Memorial Hospital in DeSoto, Mississippi, on the morning of February 7, 2011. ER staff determined she was pregnant with a possible ectopic pregnancy. She refused further examination and treatment and was released from the ER.
An ambulance brought her back to the ER at 10:25 that evening. She was again suffering from nausea and vomiting. She tested positive for marijuana and opiates. She became agitated, behaved erratically and experienced hallucinations. She was diagnosed with "acute psychosis and a drug-induced reaction to an underlying psychiatric disorder." She refused voluntary commitment and her mother consented to evaluation for involuntary commitment.
A court granted involuntary commitment for further evaluation, ordering the DeSoto County sheriff to take custody of her. Later, it ordered the Marshall County sheriff to assume custody after learning she lived there.
On February 8, 2011, DeSoto County Jail staff transferred Princess and gave Marshall County Jail officer Adella Anderson (not related to Princess) copies of Princess's medical records and the court order. She did not read them. Princess refused to answer questions during intake. Jail staff did not learn of Princess's medical condition and the possible dangerous pregnancy.
Officer Anderson placed Princess in an isolation cell. Later that night, Princess began beating the walls and acting erratically such that other prisoners asked jail officers to return her to the hospital.
On February 9th, Princess's mother filed an affidavit describing her mental condition. The court immediately appointed an attorney to represent Princess and set a hearing for two days later. A mental health evaluator visited Princess and noted she was completely disassociated and experiencing paranoid delusions placing her in "immediate danger of self-harm."
That evening, a jailer found Princess with blood on her fingers in her cell. The next day, Princess was scheduled to be transported to the physician's and psychologist's offices for a physical and mental health examination jail staff had arranged. However, a snow storm blew in causing the appointments to be cancelled and the hearing delayed for four days.
On the morning of February 9th, Princess's mother arrived at the jail with an order from the court to allow her to take Princess to the local hospital to follow up on the possible ectopic pregnancy. Jailers found Princess lying on the floor in about two inches of water, feces and vomit. Thera was blood on the cell walls and on Princess's fingertips. Her urine was black. They called 911, but she died of multisystem organ failure a few days later. The medical examiner noted a possible miscarriage in the jail.
The mother filed a federal civil rights lawsuit against Marshall County, its sheriff and the hospital. The district court granted the sheriff qualified immunity and granted the county's motion for summary judgment. Then it declined to exercise supplemental jurisdiction over the state law claims against the hospital, dismissing them without prejudice. The mother appealed.
The Fifth Circuit held that the mother had proven negligence by Officer Anderson, but this is insufficient to establish liability for the county. She had not proven the county had a policy that violated Princess's constitutional rights or that inadequate training had led to her death because jail staff should have known to call 911 sooner without additional training. Further, the district court was not required to hear the state claims wren all of the federal claims had been dismissed. Therefore, it upheld the district court's judgment. See: Anderson v. Marshall County, Mississippi, 5th Cir. No. 15-60051.
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Related legal case
Anderson v. Marshall County
| Year | 2016 |
|---|---|
| Cite | Mississippi, 5th Cir. No. 15-60051 |
| Level | Court of Appeals |
| Conclusion | Bench Verdict |
| Injunction Status | N/A |